IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE DATA CARRIERS, LLC, Plaintiff, v.

LG ELECTRONICS MOBILECOMM U.S.A., INC., LG ELECTRONICS U.S.A., INC., Defendants. COMPLAINT FOR PATENT INFRINGEMENT This is an action for patent infringement in which Plaintiff Data Carriers, LLC (Data Carriers) makes the following allegations against Defendants LG Electronics Mobilecomm U.S.A., Inc. and LG Electronics U.S.A., Inc. (Defendants). PARTIES 1. Data Carriers is a Delaware limited liability company having a principal place of JURY TRIAL DEMANDED Civil Action No. _____________

business at 1675 South State St., Ste. B, Dover, Delaware 19901. 2. On information and belief, LG Electronics Mobilecomm U.S.A., Inc. is a

California corporation with its principal office at 920 Sylvan Avenue, Englewood Cliffs, New Jersey 07632. LG Electronics Mobilecomm U.S.A., Inc. has appointed Kevin D. Jaffe, located at 10101 Old Grove Road, San Diego, California 92131, as its agent for service of process. 3. On information and belief, LG Electronics U.S.A., Inc. is a Delaware corporation

with its principal office at 1000 Sylvan Avenue, Englewood Cliffs, New Jersey 07632. LG Electronics U.S.A., Inc. has appointed United States Corporation Company, located at 2711 Centerville Road, Suite 400, Wilmington, Delaware 19808, as its agent for service of process.

JURISDICTION AND VENUE 4. This action arises under the patent laws of the United States, 35 U.S.C. 1, et

seq., including 271. This Court has subject matter jurisdiction pursuant to 28 U.S.C. 1331 and 1338(a). 2. This Court has personal jurisdiction over Defendants because, among other

reasons, Defendants have done business in this District, have filed suit in this District, have committed and continue to commit acts of patent infringement in this District, and have harmed and continue to harm Data Carriers in this District, by, among other things, using, selling, offering for sale, and importing infringing products and services in this District. 3. Venue is proper in this District under 28 U.S.C. 1391(b)-(d) and 1400(b)

because, among other reasons, Defendants are subject to personal jurisdiction in this District, have filed suit in this District, and have committed acts of patent infringement in this District. On information and belief, for example, Defendants have used, sold, offered for sale, and imported infringing products in this District. COUNT I (INFRINGEMENT OF U.S. PATENT NO. 5,388,198) 4. Data Carriers is the owner by assignment of United States Patent No. 5,388,198

(the 198 patent), entitled Proactive Presentation of Automating Features to a Computer User. The 198 patent issued on February 7, 1995. A true and correct copy of the 198 patent is attached as Exhibit A. 5. Defendants have been and now are directly and/or jointly infringing at least

claims 1 and 5 of the 198 patent, in this judicial district and elsewhere in the United States, by, among other things, making, using, importing, offering for sale, and/or selling products and services that automatically intervene in the use of a computer system to suggest or present

features based on information on the use of the system, including but not limited to autocomplete features of certain electronic devices, including smartphones, and software loaded onto and used on such devices, and www.lg.com/us. Such products and services continuously monitor and compare user manipulations and program context with feature templates stored in memory, and present automating features if a match is found. By making, using, importing, offering for sale, and/or selling such products and services, and all like products and services, Defendants have injured Data Carriers and are thus liable for infringement of the 198 patent pursuant to 35 U.S.C. 271. 6. To the extent that facts learned in discovery show that Defendants infringement

of the 198 patent is or has been willful, Data Carriers reserves the right to request such a finding at time of trial. 7. authorization. 8. As a result of Defendants infringement of the 198 patent, Data Carriers has Defendants have committed these acts of infringement without license or

suffered monetary damages in an amount not yet determined, but in no event less than a reasonable royalty for the use made of the invention by Defendants, together with interest and costs as fixed by the Court. PRAYER FOR RELIEF Data Carriers respectfully requests that this Court enter: A. A judgment in favor of Data Carriers that Defendants have infringed, directly and/or jointly, the 198 patent;

B.

A judgment and order requiring Defendants to pay Data Carriers its damages, costs, expenses, and prejudgment and post-judgment interest for Defendants infringement of the 198 patent as provided under 35 U.S.C. 284;

C.

A judgment and order finding that this is an exceptional case within the meaning of 35 U.S.C. 285 and awarding to Data Carriers its reasonable attorneys fees against Defendants;

D.

A judgment and order requiring Defendants to provide an accounting and to pay supplemental damages to Data Carriers, including without limitation, prejudgment and post-judgment interest; and

E.

Any and all other relief to which Data Carriers may show itself to be entitled. DEMAND FOR JURY TRIAL

Data Carriers, under Rule 38 of the Federal Rules of Civil Procedure, requests a trial by jury of any issues so triable by right. March 16, 2012 OF COUNSEL: Marc A. Fenster Benjamin T. Wang RUSS, AUGUST & KABAT 12424 Wilshire Boulevard, 12th Floor Los Angeles, CA 90025-1031 (310) 826-7474 mfenster@raklaw.com bwang@raklaw.com BAYARD, P.A. /s/ Stephen B. Brauerman (sb4952) Richard D. Kirk (rk0922) Stephen B. Brauerman (sb4952) Vanessa R. Tiradentes (vt5398) 222 Delaware Avenue, Suite 900 Wilmington, DE 19801 (302) 655-5000 rkirk@bayardlaw.com sbrauerman@bayardlaw.com vtiradentes@bayardlaw.com Attorneys for Plaintiff Data Carriers, LLC